POCP Blog

What Comes Next for Price Transparency? CMS RFI and New Guidance Signal Push for Accountability

Written by Vanessa Candelora | Jun 17, 2025 1:11:15 PM

In our May 2025 HIT Perspectives article, we unpacked the decade-long journey of healthcare price transparency and why most stakeholders would agree we’re still not where we need to be. Despite multiple rounds of rulemaking, patient usage of price tools remains low, and many organizations remain out of compliance with core requirements.

Now, just months after President Trump issued a new Executive Order on healthcare pricing transparency, the federal government is signaling that stronger enforcement and clearer expectations are coming.

A New Round of Guidance and Requests for Input

On May 10, the Departments of Health and Human Services (HHS), Labor, and Treasury jointly released new guidance and Requests for Information (RFIs) that aim to increase enforcement and gather feedback to inform future rulemaking. These actions reinforce priorities laid out in EO 14221 and suggest that price transparency will be a renewed area of focus across hospitals, health plans, and prescription drugs.

Key Updates Include:

  • Cracking Down on Placeholder Prices. CMS updated its Hospital Price Transparency guidance to clarify, for example, that machine-readable files (MRFs) must include actual dollar amounts for standard charges. Placeholder values like “999999999” are no longer acceptable.
  • Improving Usability Through MRF Requirements. The Departments issued an FAQ highlighting the coming updates on the requirements for Healthcare Insurers’ machine-readable files (MRFs) to drive higher usability. Changes include reducing file sizes by requiring exclusion of duplicative data, reducing unnecessary data fields, and updates to better contextualize the data, e.g. reporting of a custom place-of-service code across locations when the negotiated rate is the same.
  • Exploring New Enforcement Strategies. The open CMS RFI invites comments by 11:59 p.m. Eastern Time on July 21, 2025, on how to strengthen the enforcement of hospital transparency rules requiring MRFs. This includes feedback on how to improve MRFs' accuracy, completeness, and usability, and what support or incentives might improve compliance.
  • Expanding Prescription Drug Transparency. Agencies are also seeking input on price transparency for prescription drugs. The RFI asks for stakeholder feedback on adjustments to required data elements and formats that would be most useful, if disclosing the PBM/service providers should be required, including drugs under medical vs. pharmacy benefits, and alignment with state approaches, to name a few sticky areas. These efforts echo EO 14221’s emphasis on real-time pricing information that is “clear, accurate, and actionable”—and place a stronger onus on the industry to deliver data that patients can actually use.

Industry Impact: Evolving Expectations, Emerging Considerations

This new guidance and accompanying RFI underscore a continuing federal focus on price transparency as well as suggest a deliberate effort to refine and build upon earlier policies. So, does this impact any new stakeholders? What’s evolving from past policy?

Stakeholders already subject to the Hospital Price Transparency rule or Transparency in Coverage (TiC) regulations are still on the hook, but may see increased expectations in terms of completeness and presentation of pricing data. While these updates may require adjustments, they also present opportunities. Entities that develop consumer-facing tools, for example, may be better positioned to use this data to support more accurate cost estimates, assist with payer-provider contract negotiations, and inform revenue cycle operations.

As with any evolving policy initiative, changes may be interpreted and implemented in different ways, which could lead to outcomes that weren’t originally anticipated. While many recognize the value in price transparency as a tool to support more informed care planning, others emphasize that creating a competitive market in healthcare could have negative impacts. One potential area to monitor is whether an increased focus on pricing might inadvertently shift provider attention away from quality care, especially if incentives and transparency in quality data are not well aligned.

What Should We Be Asking For?

Following the shifts and implications discussed above, it’s important to reflect on how the industry can proactively engage with the current RFI. This is a valuable opportunity for stakeholders to share feedback based on lived experience with the policies to date—what’s worked, where gaps remain, and what improvements could help advance the goals of transparency more effectively.

As noted earlier, price transparency policy touches nearly every corner of the healthcare system. While early efforts emphasized providing raw pricing data directly to patients, it has become increasingly evident that third-party developers often play a more central role in translating this data into usable tools, whether for generating cost estimates, supporting revenue cycle operations, or informing payer-provider negotiations.

Payer and provider organizations have voiced concerns in past responses, such as those from the American Hospital Association (AHA) and AHIP. These groups have generally supported the spirit of transparency while cautioning against overly prescriptive requirements or fragmented reporting structures. Themes like regulatory alignment, clarity around data exchange expectations, and operational feasibility continue to surface in these responses and remain highly relevant as the current RFI is considered.

In responding to this RFI, stakeholders may want to focus on a few key areas:

  • Encouraging further standardization in how contract and pricing data are exchanged, to reduce administrative burden and improve interoperability.
  • Clarifying expectations for data formats and minimum fields in machine-readable files to improve usability across different systems and use cases.
  • Identifying opportunities to align price transparency initiatives with efforts around quality measurement to support a more holistic understanding of value in care.

While new formats, data elements, and adjustments will create work for payers and providers, there’s a broader opportunity here. Greater consistency in how prices for drugs, items, and services are communicated can ultimately support improved patient care and reduce friction throughout the healthcare system.

This RFI, along with others released in recent months, presents a rare window to help shape federal policy in a way that is both practical and purposeful. Whether your organization is navigating compliance, exploring strategic uses of transparency data, or contributing to industry conversations on what comes next, now is the time to get involved.

The comment period is open. Let’s use it.

Need help navigating what’s being asked—or deciding what to say?

POCP can help you understand how this latest RFI fits into the broader regulatory landscape and what it might mean for your business model. We support clients in drafting thoughtful RFI responses, identifying opportunities to align operations with upcoming expectations, and setting a strategy that leads to strategic compliance—not just box-checking.

We’re also tracking several other RFIs released this spring that touch on key areas like data governance, consent, and interoperability. If you're feeling overwhelmed by it all, let’s talk.